Expanding Canada's toolkit to address corporate wrongdoing: The Integrity Regime stream discussion guide
This consultation closed on November 17, 2017 (11:59 pm Pacific time). Submissions were accepted until December 8, 2017 (11:59 pm Pacific time).
About this public consultation
From September 25 to November 17, 2017 (submissions were accepted until December 8, 2017 (11:59 pm Pacific time), the Government of Canada invited Canadians to participate in a discussion and to provide their views on whether it has the right tools in place to address corporate wrongdoing. As part of this engagement, the government consulted with Canadians on potential enhancements to the Integrity Regime, and considerations regarding the possible adoption of a deferred prosecution agreement (DPA) regime in Canada. The following discussion paper was designed to guide the public consultations regarding the Integrity Regime.
What we heard
A summary report of what we heard during the Integrity Regime consultation process will be available in the coming weeks.
On this page
- Setting the context
- The role governments play in protecting the integrity of public procurement
- What other jurisdictions are doing
- What the Government of Canada is doing
- Principles guiding Canada's government-wide Integrity Regime
- What we have heard to date
- Possible enhancements
- 1. Time periods associated with ineligibility and suspension
- 2. Criteria for ineligibility and suspension
- 3. Addressing organized crime
- 4. Expanding the scope of application
- Summary of questions
- Provide feedback
- Contact us
Setting the context
The Government of Canada spends billions of dollars annually to buy goods and services on behalf of Canadians and to support government operations. Given the sizeable financial flows of these expenditures, contracts and real property transactions have the potential to leave the Government of Canada vulnerable to fraud, collusion and corruption. This could include, but is not limited to, bid-rigging, price fixing, bribery, undisclosed conflicts of interest, and fraudulent contract performance schemes. Public procurement is also vulnerable to organized crime, which negatively affects the daily lives of CanadiansFootnote 1.
The direct costs of these types of wrongdoing in public procurement include loss of public funds through misallocations or higher expenses, as well as lower quality of goods, services and worksFootnote 2. This can result in less available financial resources to address other priorities and further erode trust and confidence in public institutions. In a direct way, corruption in public procurement leads to distortion of competition, limited market access, and reduced business appetite for foreign investorsFootnote 2.
Internationally, a number of cases within public contracting have highlighted these risks. This has spurred renewed commitments from international bodies, such as the Organisation for Economic Cooperation and Development (OECD), the World Bank, and the United Nations, to further combat bribery and corruption.
Although it is difficult to measure the exact cost of corruption, it has been estimated that between 10 and 30% of the investment in publicly funded construction projects internationally may be lost through mismanagement and corruptionFootnote 3. The World Bank also estimates that businesses and individuals pay an estimated $1.5 trillion in bribes each yearFootnote 4.
The role governments play in protecting the integrity of public procurement
All governments have an obligation to protect and safeguard the use and expenditure of public funds, to ensure strong stewardship and transparency, and to uphold public trust. There are a number of ways that this can be achieved in the context of public procurement, including, but not limited to, debarment. Debarment is generally defined as the exclusion of an entity from receiving public contracts.
What other jurisdictions are doing
A number of jurisdictions have what is commonly referred to as a debarment regime. Although the parameters of each regime differ (for example, reasons for debarment, application of the regime, debarment periods, compliance requirements, and administration), each has a common goal of ensuring that contracts using public funds are not awarded to unethical suppliers, with varying levels of discretion.
Case study: United States of America
In the United States of America (US), the Federal Acquisition Regulation dictates circumstances in which a supplier may be debarred from receiving federal funds. The US model balances mandatory and discretionary provisions. For example, a supplier will be debarred if it is convicted under, or is in violation of a statute (such as violations of federal or state controlled substance laws; or certain violations of the Buy America Act, the Clean Air Act, or the Clean Water Act). Alternatively, a supplier may be debarred if it commits a serious violation of the terms of a government contract or certain statutes, or if there is significant evidence (typically an indictment) or any other cause so serious or compelling to justify debarment. A supplier may also be suspended from award on the basis of evidence, an investigation or charges.
Periods of debarment, where mandatory, are spelled out in relevant legislation. For discretionary debarment, a supplier may be excluded for three years and this can be extended. Each agency applies required federal regulations to its own contracting and renders their own debarment decisions, which are reported centrally. There are no monetary thresholds associated with the application of the regime. It applies to all federal funds (such as contracts, grants and contributions).
Case study: United Kingdom
The United Kingdom's (UK) debarment regime is enshrined in the European Union directives on pubic procurement and the United Kingdom Public Contracts Regulations and applies to public sector contracting authorities in the purchase of goods, supplies, and services, as well as lease to purchase agreements with varying monetary thresholds.
A supplier is debarred based on a conviction of a listed offence (such as conspiracy, corruption, fraudulent trading or money laundering) or if it is in breach of its tax and social security obligations. These mandatory debarments last five years from the date of exclusion. A discretionary debarment may take place in instances such as non-compliance with specified laws, bankruptcy, grave professional misconduct, anti-competitive behaviour, conflict of interest or poor performance. A discretionary debarment lasts three years. Self-cleaning measures may be considered to avoid exclusion from public procurement (such as paying or undertaking to pay compensation in respect to damages; clarifying facts and circumstances by collaborating with investigating authorities; taking measures to prevent further criminal offences or misconduct).
Similar to Canada, the UK government may enter into a contract with a debarred supplier if it is in the public interest to do so (such as public health or protection of the environment).
Case study: Quebec
Quebec has implemented a legislation-based certification to bid regime whereby suppliers and subcontractors apply for approval through the Autorité des marchés financiers (AMF), which works with the Unité permanente anticorruption (UPAC) (available in French only). Quebec's debarment regime currently applies to construction and public private partnership contracts over $5 million and service contracts over $1 million. Suppliers and subcontractors competing in a call for tenders or an award process equal to or greater than these thresholds must apply for approval. The AMF verifies applicants against a number of federal, provincial and other offences legislated in the Act Respecting Contracting of Public Bodies that will or may render applicants ineligible for public contracts in consultation with UPAC.
Suppliers convicted of specific offences under federal and provincial legislation are debarred for up to five years. The Authority also has wide discretion to refuse to grant or to renew an authorization or may revoke an authorization if a supplier fails to meet the high standards of integrity that the public is entitled to expect from a party to a public contract or subcontract. The Registre des entreprises non admissibles aux contrats publics (available in French only) must be consulted for public contracts to ensure that bidders are not debarred. Suppliers established outside of Quebec are required to provide a “good conduct certificate”, sworn letter, criminal or penal court record or an equivalent document when bidding.
Case study: New Brunswick
New Brunswick has implemented a legislation-based debarment regime under its Procurement Act and General Regulation. A supplier is disqualified from provincial procurement if convicted of a number of offences under six federal statutes (such as the Criminal Code, Corruption of Foreign Public Officials Act, Controlled Drugs and Substances Act). Periods of debarment last for a maximum of five years, proportional to the offence. In the case of three offences (sections 463 to 465 of the Criminal Code), the disqualification period could be more than five years, based on the set term of the sentence.
The New Brunswick regime allows for some discretion. A supplier may be disqualified for documented significant or persistent deficiencies in fulfilling or performing a substantive requirement or obligation under a prior contract or contracts.
Case study: The World Bank
When firms or individuals participating in World Bank Group-financed projects are found, through investigation, to have engaged in fraudulent, corrupt, collusive or obstructive practices on a World Bank project, the World Bank may impose a debarment. Debarred entities are then ineligible to be awarded a contract, either permanently or for a designated period of time. Decisions on how long a firm or individual is debarred are made through a two-tier adjudicative process based on the severity of the misconduct, the harm caused by the misconduct, and the past history of adjudicated misconduct. There can also be mitigating factors that influence decisions, such as a minor role in the misconduct, voluntary corrective action taken, and cooperation.
The World Bank places an emphasis on debarred parties meeting certain integrity compliance conditions before they can once again participate in World Bank Group-financed projects. These conditions encourage debarred parties to focus on rehabilitating their business practices.
What the Government of Canada is doing
The Government of Canada is committed to:
- being accountable to Canadians
- protecting the stewardship of public funds
- embodying and observing high ethical standards
- reflecting public expectations around transparency, open and citizen-centered government in procurement practices
Over time, Canada has established a strong framework to support integrity in its procurement and real property transactions, with strong governance, codes of conduct, fairness monitoring, audits, financial controls, internal investigations and, more recently, the Federal Contracting Fraud Tip Line.
In addition to these tools, Canada administers a debarment regime that has undergone a series of changes to improve its rigour and broaden its application, beginning with the introduction of the Integrity Framework in 2012.
In July 2012, Public Services and Procurement Canada (PSPC), the main contracting arm of the Government of Canada, regrouped many of its oversight measures into a formal debarment regime, the Integrity Framework. The framework applied to PSPC contracts and real property agreements and expanded on the existing Code of Conduct for Public Procurement. In addition to the offences included in the code (such as corruption, collusion, bid-rigging or fraud committed against Her Majesty), a supplier could also be rendered ineligible (term used by the Government of Canada in place of debarred) for fraud, money laundering, participation in activities of criminal organizations, income and excise tax evasion, bribing a foreign public official and offences related to drugs.
Later that same year, PSPC removed the leniency exemption from the framework, which previously allowed an applicant to come forward, cooperate and plead guilty in exchange for lenient treatment in sentencing, and introduced a public interest exception.
In February 2014, nine new offences were added to the framework including:
- bribery of judicial officers
- bribery of officers
- secret commissions
- criminal breach of contract
- fraudulent manipulation of stock exchange transactions
- prohibited insider trading
- forgery or other offences resembling forgery
- falsification of books and documents
The ineligibility period for a supplier convicted of or having pleaded guilty to an Integrity Framework offence was ten years with no exceptions. In addition, suppliers who were convicted of a similar foreign offence were also debarred from contract award. Finally, suppliers were required to bind their subcontractors to the same terms and conditions listed in their contract or lease agreement with PSPC.
In July 2015, the Government of Canada introduced an updated Integrity Regime to foster ethical business practices, ensure due process and uphold the public trust. Unlike its predecessor, the regime applies to contracts and real property agreements awarded by all federal departments and agencies under Schedule I, I.1 and II of the Financial Administration Act, with some exceptions. This drastically expanded the scope of application. The regime is articulated in the Ineligibility and Suspension Policy and Integrity clauses.
Key features of the regime are as follows:
- a supplier convicted of a listed offence in Canada or a similar offence abroad is ineligible for a period of ten years to enter into a contract or real property agreement with the government
- a supplier can apply to have their ineligibility period reduced by up to five years if they address the causes of the conduct that led to ineligibility
- a supplier is not automatically penalized for the actions of an affiliate in which they had no involvement
- a supplier may be suspended for a period of up to 18 months if it has been charged with a listed offence or has admitted guilt. This period may be extended as judicial processes proceed
- procedures incorporate consideration of due process
- provides for the use of independent expert third-party assessments, and administrative agreements that specify required corrective actions and ensure their effectiveness by monitoring compliance
In April 2016, an updated version of the Ineligibility and Suspension Policy and Integrity clauses were released. While there were no changes to the Integrity Regime itself, the policy and clauses were simplified in response to feedback from client departments and agencies, as well as the supplier community. The clauses now incorporate the policy by reference into solicitation documents and resulting contracts and real property agreements.
In order to foster transparency and accountability, the ineligibility and suspension list is publicly available on the Integrity Regime website and the government does regularly report on the activities and achievements of the Integrity Regime.
Principles guiding Canada's government-wide Integrity Regime
Through various efforts to protect the integrity of federal procurement and real property transactions, the Government of Canada has been guided by the following five principles:
- safeguard the expenditure of public funds within procurement and real property transactions
- conduct business in an open, fair, transparent, accountable and cost-efficient manner
- ensure rigour and due process without imposing undue administrative burden on suppliers or the Government of Canada
- promote ethical conduct by suppliers within the marketplace
- ensure consistent government-wide application while preserving operational efficiencies
What we have heard to date
Since the introduction of the Integrity Regime in 2015, the Government of Canada has engaged major industry associations, professional organizations (such as law firms and accounting firms), suppliers, and civil society groups to solicit feedback on implementation, and provide clarification on elements of the regime. Reaction has been generally positive, however some changes have been suggested to strike a better balance between holding wrongdoers accountable for their actions, incenting early detection and reporting when problems arise, and allowing some discretion to mitigate negative impacts on innocent parties. This includes proposed changes to timelines and criteria associated with ineligibility and suspension; increased discretion; and, possible expansion of the scope of the regime.
From September 25 to November 17, 2017 (submissions were accepted until December 8, 2017 (11:59 pm Pacific time) interested parties were invited to share their views on the 4 possible enhancements listed below. Submissions were accepted until December 8, 2017 (11:59 pm Pacific time).
After five years of experience administering a debarment regime, and based on feedback received and best practices from other jurisdictions, the following are a series of possible enhancements to the Integrity Regime for consideration. Each concept includes a short description of what the enhancement could look like in practice, followed by questions for input.
1. Time periods associated with ineligibility and suspension
Concerns have been raised regarding the time periods associated with suspension and ineligibility. For example, the ten-year period of ineligibility has been criticized as being punitive, disproportional, and not aligned with international best practices. Questions remain as to whether these time periods should be reduced, or if they should be made discretionary and based on the nature and context of the offence.
Under the current regime, discretion within the determination process is limited, as much of the policy is rules-based. For example, if a supplier is convicted of one of the listed offences in Canada or of a similar offence abroad within the last three years, the supplier will automatically be ineligible to be awarded a federal contract or real property agreement for a period of ten years. There is some discretion when dealing with a conviction of an affiliate in that the supplier may be determined to be ineligible; however, only if they directed, influenced, authorized, assented to, acquiesced in or participated in the commission of the offence of the affiliate.
There is also discretion to reduce a supplier's period of ineligibility by up to five years if it can demonstrate that they have cooperated with law enforcement or have taken steps to address the causes of the conduct that led to their ineligibility.
The periods of ineligibility are fixed (for example, ten years) regardless of the offence that triggered the determination or the circumstances associated with the situation.
Other jurisdictions have greater levels of discretion built into their debarment regimes. In the US, the debarring official at the federal agency level, when making a decision to debar a supplier or affiliate, applies discretionary measures on a case-by-case approach with supportive evidence. In addition to assessing the business risk to the US government, the debarring official assesses whether the supplier is "presently responsible", meaning whether the supplier's management recognizes and understands the seriousness of the misconduct giving rise to the cause for debarment, and whether the supplier has implemented programs to prevent a recurrenceFootnote 4.
To what extent, if any, should the duration of ineligibility and/or suspension be modified to ensure appropriateness while continuing to mitigate risk?
How could the exercise of greater discretion be built into the Integrity Regime to address issues associated with periods of ineligibility? What factors should be considered in determining whether a supplier should benefit from discretion?
2. Criteria for ineligibility and suspension
The Ineligibility and Suspension Policy sets out criteria that trigger a determination of suspension or ineligibility. These decisions are rendered on the basis of specific charges and convictions, all of which are criminal in nature, relate to corporate wrongdoing, and are specified federal offences.
Currently, the Ineligibility and Suspension Policy includes offences under the following legislation:
- Criminal Code
- Competition Act
- Controlled Drugs and Substance Act
- Corruption of Foreign Public Officials Act
- Excise Tax Act
- Financial Administration Act
- Income Tax Act
- Lobbying Act
The Regime does not take into account:
- civil or provincial offences
- other federal offences associated with corporate wrongdoing
- allegations or investigations
- debarment decisions made in other jurisdictions
The absence of these considerations could leave federal contracts and real property agreements susceptible to increased risk.
Provincial and civil offences
A supplier that is charged with or convicted of criminal conduct similar to the specified federal offences contained in the Ineligibility and Suspension Policy by either a province or other subnational body does not face the same consequences under the Integrity Regime. For example, a supplier could be convicted of tax fraud in a particular province, but remain eligible under the federal Integrity Regime.
Furthermore, in some cases, other jurisdictions may prosecute corporate wrongdoing civilly rather than criminally. For example, in many European countries, wrongdoing associated with collusion and bid-rigging are civil offences. In some countries, such as Germany and Sweden, corporations are not subject to criminal prosecutions as they are not recognized as a natural person.
This represents a potential gap in the application of the Regime, treats suppliers inconsistently and as such, may present a risk in the context of federal procurement and real property agreements. For example, while a supplier may exhibit the same conduct or behaviour, it may face different consequences under the Regime depending on how the offence is treated in the jurisdiction in which the wrongdoing is prosecuted.
Additional offences associated with corporate wrongdoing
To further safeguard the integrity of its contracts and real property agreements, the Government of Canada could also consider adding new federal offences to the Ineligibility and Suspension Policy that are linked to corporate wrongdoing. This could include other fraud-related offences or those calling into question the integrity of the supplier.
Are there other offences that call into question the integrity of a supplier that should be considered for inclusion within the Ineligibility and Suspension Policy? If so, what are they?
What factors should be considered in determining whether new offences should be included?
Taking action prior to, or in the absence of a conviction
The reliance on charges and convictions to trigger a determination of suspension or ineligibility potentially limits the Government of Canada's ability to take action to protect the integrity of its contracts and real property agreements prior to a formal conviction, where the risks are potentially higher.
The risks to the government are potentially greater in doing business with a supplier that is under investigation or the subject of allegations regarding business ethics, than following a conviction many years later. By that time, a supplier could have taken remedial actions to address the issues around the allegations of wrongdoing.
Regimes in other jurisdictions allow for debarment in the absence of formal charges or convictions. For example, in the US a supplier may be suspended from federal procurement on the basis of adequate evidence, temporarily pending the completion of an investigation, when it has been determined that immediate action is necessary to protect the government's interestFootnote 5. This enables US officials to take action to mitigate risks and protect the integrity of its contracts when problems first arise.
At what point should the Government of Canada consider actions regarding corporate wrongdoing when making a determination of suspension or ineligibility? What wrongdoing or action would warrant a federal response?
Application to non-procurement Government of Canada services
Decisions under the Ineligibility and Suspension Policy could also affect a company's eligibility for certain Government of Canada services outside of procurement. For example, Global Affairs Canada's Trade Commissioner Service (TCS) provides market information, qualified contacts, advice and support to eligible Canadian companies in their business endeavours abroad. These services are provided on a discretionary basis by the TCS, which has its own eligibility criteria and a standard operating procedure to determine whether a company may receive its services. Triggers for ineligibility for TCS support include a criminal conviction in Canada for bribery or corruption and debarment by an international financial institution, such as the World Bank. The TCS has the discretion to withdraw services for other reasons, which may include, for example, a suspension or declaration of ineligibility under the Ineligibility and Suspension Policy.
As part of its standard operating procedure, the TCS requires companies to sign an Integrity Declaration before receiving any advocacy support. The TCS aims to bring economic benefit to Canada by supporting Canadian companies that do business responsibly and ethically, while showcasing Canada as a positive example in responsible business practices.
How should Integrity Regime determinations of ineligibility be applied to non-procurement federal services?
Other jurisdictions' debarment decisions
The Government of Canada could consider using debarment decisions made in other jurisdictions (for example, Canadian provinces and territories with debarment regimes, the US, the UK, or the World Bank) to assess whether or not it is in the government's best interest to do business with a debarred supplier. This could be particularly useful in the Canadian context to avoid inconsistencies resulting from the Government of Canada continuing to contract with a supplier debarred by a province or territory.
This practice, also known as cross debarment, is in place among five multilateral development banks (Asian Development Bank Group, African Development Bank, European Bank for Reconstruction and Development, Inter-American Development Bank Group and the World Bank Group). Effectively, a supplier debarred by one development bank is ineligible to contract with all of themFootnote 6.
The World Bank suggests that cross debarment multiplies the deterrence factor of a single sanction and allows participating institutions to make the most of limited investigative resources. The increased transparency and uniformity of the sanctions process also helps suppliers have a better understanding of what is expected of themFootnote 6.
What impact should a debarment decision made in another jurisdiction or by another organization have on a supplier's status under the Integrity Regime?
3. Addressing organized crime
Organized crime poses a significant threat to public safety and negatively impacts the daily lives of Canadians. Tied to illegal activities such as drug trafficking, prostitution, theft and human trafficking, organized crime groups have a violent and corrupting effect on the communities and cities where they operateFootnote 1. Public procurement is also susceptible to the infiltration of organized crime and its negative consequences.
Under the Integrity Regime, a supplier may be determined to be suspended or ineligible for a charge or conviction under sections 467.11 to 467.13 of the Criminal Code (that is, participation in the activities of a criminal organization, recruitment of members by a criminal organization, commission of offence for criminal organization and instructing commission of offence for criminal organization). As there are known linkages between illicit drugs and organized crime, a supplier may also be suspended or ineligible if charged with, or convicted of an offence under sections 5 to 7 of the Controlled Drugs and Substances Act (trafficking in substance; importing and exporting; and production of a substance).
Some have suggested that relying on charges or convictions under these sections of the Criminal Code does not to go far enough to protect the Government of Canada from doing business with suppliers who are affiliated with organized crime.
What type of measures should be taken to preclude those with known membership in or associations with organized crime from being awarded a federal contract or real property agreement?
4. Expanding the scope of application
There is an opportunity to look beyond the current scope of the Integrity Regime with respect to how it applies to contracts and real property agreements awarded by organizations affiliated with the Government of Canada, and if it can be used to achieve other policy objectives of interest to Canadians.
Application to other federal organizations
At this time, the Integrity Regime applies to all federal departments and agencies identified under Schedules I, I.1 and II of the Financial Administration Act. Other federal entities, such as Crown Corporations, are encouraged to opt in to the Integrity Regime.
Broader adoption of the Integrity Regime to other federal organizations' procurement and real property transactions would provide greater assurances that the Government of Canada is not conducting business with unethical suppliers.
Using the Integrity Regime to achieve other purposes
It has been suggested that the Government of Canada use its purchasing to positively and uniformly influence corporate behaviour. Increasingly, international bodies and national/sub-national governments are incorporating provisions to ensure respect for human and labour rights protection in procurement decisions and policy.
For example, in the US, a supplier may be debarred if it engages in conduct prohibited under federal statutes such as the Buy American Act, the Clean Water Act and the Clean Air Act. In addition, the US has issued a series of presidential executive orders that augment ethical procurement standards. This includes, but is not limited to:
- requiring federal contractors who supply items included on a list of products, by country of origin, which may have been made by forced or indentured child labour to certify that they have made a good faith effort to determine whether forced or indentured child labour was used to produce the items
- imposing a variety of prohibitions on suppliers and subcontractors who engage in activities which usually constitute or may lead to some form of trafficking (such as commercial sex, forced labour, fraud or the worst forms of child labour)
In the UK, a longstanding discussion on the use of forced labour in supply chains has led to the adoption of the Modern Slavery Act which requires companies with a global turnover of 36 million British pounds or more to disclose actions undertaken to eliminate modern slavery in their own business or end-to-end supply chains. There is growing pressure for the UK to require all suppliers to the government to include a similar disclosure when bidding on a public procurement.
The Government of Canada could consider adding to the Integrity Regime offences related to social issues such as forced labour and labour rights violations, human trafficking and environmental infractions.
Should application of the Integrity Regime be broadened to include federal entities beyond departments and agencies? What factors should be considered when determining what other organizations should be required to adopt the Integrity Regime?
How could the Government of Canada use the Integrity Regime to achieve other social, economic or environmental policy objectives?
Summary of questions
We are interested in your views and welcome detailed responses regarding the questions set out in this discussion paper, a summary of which can be found below.
- Question 1: To what extent, if any, should the duration of ineligibility and/or suspension be modified to ensure appropriateness while continuing to mitigate risk?
- Question 2: How could the exercise of greater discretion be built into the Integrity Regime to address issues associated with periods of ineligibility? What factors should be considered in determining whether a supplier should benefit from discretion?
- Question 3: Are there other offences that call into question the integrity of a supplier that should be considered for inclusion within the Ineligibility and Suspension Policy? If so, what are they?
- Question 4: What factors should be considered in determining whether new offences should be included?
- Question 5: At what point should the Government of Canada consider actions regarding corporate wrongdoing when making a determination of suspension or ineligibility? What wrongdoing or action would warrant a federal response?
- Question 6: How should Integrity Regime determinations of ineligibility be applied to non-procurement federal services?
- Question 7: What impact should a debarment decision made in another jurisdiction or by another organization have on a supplier's status under the Integrity Regime?
- Question 8: What type of measures should be taken to preclude those with known membership in or associations with organized crime from being awarded a federal contract or real property agreement?
- Question 9: Should application of the Integrity Regime be broadened to include federal entities beyond departments and agencies? What factors should be considered when determining what other organizations should be required to adopt the Integrity Regime?
- Question 10: How could the Government of Canada use the Integrity Regime to achieve other social, economic or environmental policy objectives?
This consultation closed on November 17, 2017 (11:59 pm Pacific time). Thank you to all those who participated in this consultation process.
- Government of Canada
- Portage III, Tower A 10A1
11 Laurier St
Gatineau QC K1A 9S5
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